Exhibit 2020-05-29 Discovery Excerpt — Agent Fee Litigation (Dkt. 52.4)

Summary

Exhibit 4, a set of Plaintiff's Consolidated Discovery Requests to Defendant Synovus Bank in Sport & Wheat CPA PA v. ServisFirst Bank Inc., Synovus Bank, et al., Case No. 3:20-cv-5425-TKW-HTC, in the U.S. District Court for the Northern District of Florida, Pensacola Division. The plaintiff, suing individually and on behalf of a class, serves the requests on Synovus Bank. The instructions call for electronically stored information in native format with materials needed to interpret it, and define terms such as "all," "any" and "each". The requests for production seek PPP-related documents and communications between the bank and the plaintiff, documents containing the plaintiff's name, the bank's loan files for borrowers that used the plaintiff as a PPP Agent, and communications with such borrowers.

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Full text

EXHIBIT 4
                IN THE UNITED STATES DISTRICT COURT
               FOR THE NORTHERN DISTRICT OF FLORIDA
                        PENSACOLA DIVISION

SPORT & WHEAT CPA PA,
a Florida corporation, individually and
on behalf of a class of similarly situated
businesses and individuals,

        Plaintiff,
                                             Case No. 3:20-cv-5425-TKW-HTC
v.

SERVISFIRST BANK INC.;
SYNOVUS BANK; et al.,

        Defendants.

     PLAINTIFF’S CONSOLIDATED DISCOVERY REQUESTS TO
                 DEFENDANT SYNOVUS BANK

        Plaintiff serves these consolidated discovery requests on Defendant Synovus

Bank.

                                  INSTRUCTIONS

        1.     All electronically stored information is to be produced in its unaltered

native format.

        2.     If information stored in, or accessible through, computers or other

data retrieval systems is produced, it must be accompanied with instructions and all

other materials necessary to use or interpret such data, including any data

dictionaries or other descriptive materials.



                                             1
      15.      The use of the singular form includes the plural and vice versa.

      16.      The terms “all,” “any,” and “each” shall each be construed as

encompassing any and all.

                          REQUESTS FOR PRODUCTION

      1.       Every PPP-related document and communication exchanged between

the Bank and Plaintiff.

      2.       Every document that contains Plaintiff’s name or other identifying

information.

      3.       The file the Bank maintains for each PPP Loan for any Borrower

where Plaintiff was used as a PPP Agent, including but not limited to: the PPP Loan

application itself; all communications with anyone regarding that particular PPP

Loan; all documents prepared and sent to or from the Small Business

Administration; any internal correspondence, e-mails, or notes within the Bank

regarding that PPP Loan.1

      4.       Every PPP-related document and communication exchanged between

the Bank and any Borrower whom the Bank knew or believed was using Plaintiff as

a PPP Agent.


1
 On request, Plaintiff will supply the Bank with sufficient information to identify all
such Borrowers.


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